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VII. Summary of the Evidence

B. Summary Of The Testimony
Of Ron Peters

1. Summary of Corroboration
of Peters' Testimony

¤ Ron Peters'
testimony is corroborated by the testimony of James
Eveslage who voluntarily told us that he arranged for
Peters to accept Pete Rose's betting through Gioiosa.

¤ Ron Peters'
testimony is also corroborated by Mike Fry. Fry
observed Gioiosa placing bets for Pete Rose while
Gioiosa was the Manager of Gold's Gym, which Fry
owned. Fry voluntarily admitted loaning Pete Rose
$17,000 and $30,000 in the fall of 1985, after the
baseball season, to pay Rose's gambling losses. Fry
admitted cashing checks for Gioiosa in February 1986
in order for Gioiosa to pay Peters. Fry's endorsement
appears on the checks. Fry further stated Gioiosa and
Janszen could not have afforded to bet $2,000 per
game with Peters. Fry stated that he went with Pete
Rose and Gioiosa to visit Jonathan' s Cafe.

¤ Ron Peters'
testimony is also corroborated by Lance Humphrey, the
daytime manager of Gold's Gym. Humphrey testified
that Gioiosa told him that he was betting for Rose on
baseball, basketball and football with Ron Peters at
$1,000 to $5,000 per game. Humphrey testified that
Gioiosa could not afford to place bets of that size.

¤ Ron Peters'
testimony is corroborated by the telephone records of
Gold's Gym for 1986 which show sixty-five telephone
calls from Gold's Gym to Ron Peters during the 1986
baseball season, when Tommy Gioiosa was manager of
Gold's Gym.

¤ Ron Peters'
testimony is corroborated by the three $8,000 checks
signed by Pete Rose on February 5, 1986, endorsed by
Fry and cashed by Gioiosa.

¤ Ron Peters'
testimony is corroborated by Rose's $34,000 check,
dated March 12, 1987, signed by Reuven Katz, and
endorsed and cashed by Tommy Gioiosa.

¤ Ron Peters'
testimony is corroborated by the phone records of
Rose, Janszen and the Cincinnati Reds, and by the
hotel bills of Pete Rose during May, June and July
1987. These records show a pattern of telephone
traffic prior to the beginning of each Reds game --
home or away, night or day -- between Janszen,
Marcum, Rose and Peters.

¤ Ron Peters'
testimony is corroborated by the sworn admissions of
Pete Rose during his deposition. Rose testified that
he gave his bets to Gioiosa to place with a
bookmaker; that he had Gioiosa pay his gambling
losses and collect his winnings; that he signed the
three $8,000 checks on February 5, 1986 for Gioiosa
to pay his gambling losses; that he directed his
attorney, Reuven Katz, to give a $34,000 check to
Gioiosa to pay his gambling losses; that he cannot
explain how a copy of the $34,000 check was in the
possession of Ron Peters and Paul Janszen in May
1987; that he did send Mike Bertolini eleven checks
totaling $88,000 in October, November and December
1986, which is the time when Gioiosa told Peters that
Pete Rose was unable to pay Rose's $34,000 debt to
Peters due to Rose's indebtedness to a Mafia
bookmaker in New York; that he visited Jonathan's
Cafe with Gioiosa, where he gave an autographed bat
to Ron Peters for his restaurant and Gioiosa met with
Peters in a back room; and that he ordered tickets to
Reds games for Peters in 1986 and 1987, which he
explained by saying that someone else must have asked
him for the tickets.

¤ Ron Peters'
testimony is corroborated by the transcript of his
conversation with Rose's counsel, Robert Pitcairn, on
March 13, 1989, prior to any publicity about Peters.
Pitcairn returned Peters' call to Katz and made
inquiries about the Commissioner's investigation
without asking Peters who he was and without
disputing Peters' statement that Pete Rose bet with
him.

¤ Ron Peters'
testimony is corroborated by the voluntary sworn
testimony of Paul Janszen and Danita Marcum who
testified that they placed bets of $2,000 per game at
the request of Pete Rose with Ron Peters on the Reds
and other baseball games during May, June and July
1987.

¤ Ron Peters'
testimony is corroborated by betting sheets obtained
from Rose's home and found by an expert to be in
Rose's handwriting. The betting sheets contain a
listing of Major League Baseball games, including the
games of the Cincinnati Reds, with the results.

¤ Ron Peters'
testimony is corroborated by the voluntary sworn
testimony of Jim Procter and Dave Bernstein. Procter
overheard Rose betting on baseball games with Paul
Janszen, and Bernstein was advised by Janszen in the
spring of 1987 that Rose was betting on baseball and
the Reds with Ron Peters.

¤ Ron Peters'
testimony is corroborated by his own betting records,
which show bets on the Reds and other baseball games.
The records also indicate that Peters had only one
baseball betting customer in 1987. These records also
bear the names of "Pete" and Janszen in
Peters' handwriting.

¤ Ron Peters'
testimony is corroborated by the report of the
gambling expert who authenticated and verified
Peters' betting records for 1987. His report states
that Peters had only one customer during that season.

¤ Ron Peters'
testimony is corroborated by the telephone toll
records from Pete Rose's home and hotel room during
May and June 1987. The records reveal telephone calls
to Ron Peters' telephone number before the start of
the games of the Cincinnati Reds.

It should be noted that Ron Peters
bears no animus toward Pete Rose -- Peters recovered his
1986 losses on baseball betting by not paying Rose the
$34,000 in 1987. Ron Peters gained nothing by his
voluntary sworn statements against Rose. Ron Peters gave
this testimony about Pete Rose against Peters' penal
interest, that is, Peters' statements were incriminating
and exposed him to prosecution for conducting an illegal
bookmaking operation. Admissions against penal interest
are considered trustworthy under the Federal Rules of
Evidence. His testimony and his voluntary pleas of guilty
to federal offenses are acts of integrity.

I find Ron Peters worthy of belief
in view of the independent corroboration of his
testimony.